Barclays US and European Banks Shaken, and Stirred

Special Report
30 March 2023
US and European Banks
Shaken, and stirred FOCUS

#BankingFallout
The collapse of Silicon Valley Bank in the US and Credit Suisse
in Europe has shaken confidence in the Western banking
system. We think that what happened was idiosyncratic and will Credit Research
Peter Troisi(i)
prove well contained, but we do expect a broader contraction in +1 212 412 3695
[email protected]
credit, given tighter lending standards and increases in funding BCI, US
costs. Soumya Sarkar(i)
+ 44 (0) 20 7773 0315
• US and European banks remain liquid and well capitalized; we calculate an average [email protected]
Barclays, UK
liquidity coverage ratio (LCR) for US banks of 118% and 160% for Europe.
David Alam(i)
• However, credit contraction is likely to materialize as lending standards tighten, due to + 44 (0) 20 7773 6579
greater conservatism. We think that US regional banks, which held 45% of US commercial [email protected]
and industrial loans at end-2022, are likely to increase their loan-to-deposit ratios as they Barclays, UK
grow more circumspect in growing their loan books.
Equities - U.S. Large-Cap Banks
• System credit is also likely to contract via higher costs of funding, by way of higher costs of Jason M. Goldberg, CFA
deposits and capital. We estimate that US deposit beta is tracking at 30% and Europe’s at +1 212 526 8580
[email protected]
19%, lower than the 40-70% in previous cycles. Confidence in the AT1 instruments, in the
BCI, US
context of general creditor hierarchies, will likely require time before it recovers. This adds to
widening CDS spreads, implying a higher cost of issuance. Equities - European Banks
Grace Dargan
• For both US and Europe, regulatory oversight is also likely to tighten, which will make +44 (0)20 3555 4065
banks safer, but at the expense of credit availability to the economy. [email protected]
Barclays, UK
Amit Goel
+44 (0)20 3134 6375
[email protected]
Barclays, UK
Paola Sabbione
+39 (0)2 6372 2579
Barclays Capital Inc. and/or one of its affiliates does and seeks to do business with companies [email protected]
covered in its research reports. As a result, investors should be aware that the firm may have a BBI, Milan
conflict of interest that could affect the objectivity of this report. Investors should consider this
report as only a single factor in making their investment decision.
This research report has been prepared in whole or in part by equity research analysts based
outside the US who are not registered/qualified as research analysts with FINRA.
This is a Special Report that is not an equity or a debt research report under U.S. FINRA Rules 2241-
2242.
This author is a debt research analyst in the Fixed Income, Currencies and Commodities Research
(i)
department and is neither an equity research analyst nor subject to all of the independence and
disclosure standards applicable to analysts who produce debt research reports under U.S. FINRA
Rule 2242.
FOR ANALYST CERTIFICATION(S) PLEASE SEE PAGE 21 .
FOR IMPORTANT EQUITY RESEARCH DISCLOSURES, PLEASE SEE PAGE 21 .
FOR IMPORTANT FIXED INCOME RESEARCH DISCLOSURES, PLEASE SEE PAGE 22 .
Completed: 29-Mar-23, 18:55 GMT Released: 30-Mar-23, 04:00 GMT Restricted - External
Barclays | US and European Banks
A case of duration mismatch at Silicon Valley Bank

(SVB)
In 2020 and 2021, venture capital and private activity reached record highs, aided by historically
low interest rates. With the pandemic driving increased digital adoption and a heightened focus
on healthcare, fund raising was concentrated in the technology and health care & life science
sectors, where SVB focused. Over these two years, SVB’s deposits surged $127bn, or 206%,
despite an uncertain macro backdrop. This meaningfully outpaced the US banking industry’s
strong deposit growth of 35%. SVB also had a fairly unique deposit base, with very few retail
customers. As a result, a high proportion of its deposits was above the $250,000 level and
uninsured by the FDIC. In addition, over 60% was tied to companies in technology and health
care & life sciences, while another 12% was with venture capital and private equity firms.
The search for yield

Given SVB’s desire to seek a higher yield than cash, as fed funds was at the zero lower bound, it
plowed over three-quarters of its deposit growth into fixed-rate US Treasury and mortgage-
backed securities. Over this period, its securities portfolio ballooned by $99bn, or 337%. Of this
increase, 85% was classified as held-to-maturity (HTM) and only 15% as available-for-sale (AFS).
While HTM valuations do not affect its capital or income, these longer-dated assets created
significant duration risk, as the Federal Reserve began to hike interest rates aggressively early in
2022 to combat inflation. Public markets declined, the IPO window closed and venture capital
investments fell. As a result, companies across all investment stages experienced challenges
accessing liquidity.
A reduction in client fundraising, coupled with increased burn rates at its customers, weighed
on SVB’s deposit growth. In 2022, deposits fell 9% , with non-interest bearing deposits dropping
36%, which had to be replaced with higher-cost funding, weighing on its net interest margin. In
addition, as the Federal Reserve hiked, unrealized losses on its securities increased. At year-end
2022, in its AFS portfolio these stood at $2.5bn, while for the HTM portfolio, it was $15.1bn. In
fact, unrealized HTM losses exceeded its tangible equity of $11.8bn. The estimated weighted-
average duration of its fixed income investment securities portfolio was 5.7 years, or 5.6 years
including the effect of its fair value swaps. A long duration securities portfolio compared with
the short duration of deposits, with minimal hedging, came back to haunt SVB.
FiGUrE 1. Uninsured domestic deposits as percent of total deposits FiGUrE 2. SVB unrealized losses, 1Q20-4Q22 ($bn)
(ex-trust banks), 4Q22
100% $5
90%
80% $0
70%
60% -$5
50%
40%
-$10
30%
20%
10% -$15
0%
-$20
CMA
FRC
ZION
PNC
TFC
USB
CFG
KEY
RF
C
HBAN
MTB
GS
WFC
COF
ALLY
FITB
JPM
SIVB
BAC
MS
1Q20 1Q21 1Q22

AFS Unrealized Gains/Losses HTM Unrealized Gains/Losses
Source: Company reports, S&P Global Market Intelligence, Barclays Research Source: Company reports, S&P Global Market Intelligence, Barclays Research
30 March 2023 2
Pressures continued into 2023. Client cash burn remained elevated and increased further in
February, resulting in lower-than-expected deposit levels. In the first two months of the year,
deposits dropped another 5%, driven by a reduction in non-interest bearing deposits. The
continued shift in funding mix to higher-cost deposits and short-term borrowings, coupled with
higher interest rates, continued to pressure SVB’s net interest income and margin.
When all things collided, and failed

In March, SVB lowered its 1Q23 and 2023 outlook. To soften this reduction, it sold $21bn of US
Treasury and agency securities from its AFS portfolio. These were yielding a low 1.79%. It
planned to reinvest the proceeds into short-duration US Treasuries hedged with receive-floating
swaps. This was supposed to add $450mn to annualized net income. The sale, however, was to
result in a $1.8bn after-tax loss. To combat the magnitude of the capital hit, it intended to raise
$2.25bn in common equity/mandatory converts in a transaction expected to price after a day of
marketing. Under its plan, the sold securities and raised capital were not going to depositors
(although it would have increased the liquidity of its AFS book for future potential outflows).
An EPS guide down, selling securities at a loss (before raising required capital), a capital raise
plan that did not materialize, the bulk of deposits being not insured, a high proportion of HTM
securities with a large unrealized loss, a large proportion of customers in like industries
overseen by similar VC and PE funds, a multi-year period of rapid growth, social media and
instant messaging, and a neighboring bank closing down (on the same night, Silvergate
announced its intent to wind down operations and voluntarily liquidate its bank) was not a
healthy combination. As is well known, SVB never raised the capital, had massive deposit
outflows (25% the next day), and was put into receivership as it ran out of money amid a crisis
of confidence. It marked the second-largest bank failure ever, after Washington Mutual in 2008.
SVB clearly underestimated how its concentrated depositors would react to its securities losses,
the planned capital raise and declining stock price (for an outside observer, the stock price,
rightly or wrongly, is an easy way to evaluate a bank’s health).
A series of unfortunate events for Credit Suisse (CS)

Credit Suisse was subject to intense funding pressure and capital needs throughout 2022, after
poor profitability in recent years affected by litigation risks and governance issues (such as
Archegos and Greensill). This culminated in a new strategic plan, unveiled 27 October 2022,
which aimed to rebalance CS away from its investment bank and more towards wealth
management. This came alongside a capital increase of CHF4bn to restore Credit Suisse’s CET1
capital ratio to 14% by end-2022.
After raising fresh capital, solvency was not an immediate issue. Instead, the market’s attention
turned to potential liquidity issues and outflows. CS experienced significant deposit outflows of
CHF138bn in Q4 22, which its chairman said was driven by a “social media storm.”1
CS continued to be the subject of a significant amount of negative headlines in 2023. Although

each headline in isolation did not have a material financial effect, the combined news flow,
especially after SVB’s fallout, shook depositor and investor confidence in the bank. In its final
week before government intervention, Credit Suisse reportedly experienced deposit outflows of
up to CHF10bn per day.2
The creation of a unique merger with UBS, with AT1s written down
Four days after FINMA and SNB gave a joint statement that “Credit Suisse meets regulatory
capital and liquidity requirements,” regulators welcomed the takeover of Credit Suisse by UBS
1
Financial Times, 1 December 2022. https://www.ft.com/content/1840027b-f26a-4d07-9727-8b9b18a92535
2
Financial Times, 18 March 2023. https://www.ft.com/content/5746165a-3a0c-42c7-9a2e-cb7cf5f33f46
30 March 2023 3
because “there was a risk of the bank becoming illiquid, even if it remained solvent.” This
highlights that the regulator’s assessment (and market’s perception) of a bank’s liquidity
position can change rapidly in a matter of days.
The most significant outcome for bondholders was the full write-down of CHF c.16bn AT1
instruments, while shareholders received CHF3bn, in a seeming violation of the creditor
hierarchy that shareholders should absorb losses before bondholders. FINMA later announced
that CS AT1s were written down based on a “Viability Event” in the instrument’s documents and
by the passage of an Emergency Ordinance law on 19 March.
We believe US banks are well supported in face of

uncertainty
Traditionally, banks have been thought to have stable liabilities (deposits), which fund assets
with credit risk (loans). Events this month have reminded investors that asset-liability
management (ALM) at banks is not that simple. Sharply increasing interest rates caused enough
pressure on SVB to deploy aggressive financial policies. Its failure exposed the sensitivity of
certain types of banking funding, including uninsured deposits, which account for roughly 45%
of the aggregate in US banks.
Heightened awareness of the risk of deposit liabilities was exacerbated by acute market focus
on asset duration. Banks, particularly US regionals banks, have grown their fixed income
portfolios as a way to invest excess liquidity that exceeded customer demand for loans.
Admittedly, it is not obvious how they manage duration risk from analyzing their financial
statements. ALM is a rigor applied across the balance sheet employing multiple techniques in a
holistic approach. For example, securities portfolio duration can be mitigated by floating-rate
loans and/or fixed-rate term deposits. Many banks also hedge asset duration with swaps,
although the benefit is hard to quantify. Either way, while it is clear that SVB had risk
management shortfalls, we believe most US banks have tight controls on duration risk.
Failures were isolated and should remain so

Despite growing pressure on banks’ balance sheets from a sharp rise in interest rates, only a few
failed (Facing Stress from Both Sides of the Balance Sheet). Why was that? Deposit redemptions,
in fact, did occur at smaller banks,3 with Fed data showing their deposits dropped 1.9%, or
$108bn from March 8-15. However, these outflows were met with an abundance of available
liquidity, including from the central bank, and prevented regionals from resorting to forced
sales of depreciated securities. The most recent Fed H8 data indicate that deposit loss this
month has been manageable for the US banking sector (see HG Banks: What if the Big Get
Bigger?). Although we see deposit betas rising, we think contagion risk from the banks that have
failed or are already in distress is much lower, given the attention of central banks.
Asset quality will be in focus over the medium term

Immediately after the failure of SVB, investor focus was on the mismatch between banks’
liabilities and their high-quality assets. However, as it became clear that most banks would
survive the crisis, attention turned to other potential risks on the balance sheet. The credit
performance of loans held by banks has started to normalize after several years of pristine asset
quality. We do not expect the trajectory of normalization to be materially affected by this
episode. However, some types of assets that banks finance are under more pressure than
others.
As discussed in this report, commercial real estate (CRE) prices are under pressure, and US
banks are the largest holders of CRE debt (Figure 3). CRE loans represent about 20% of loans
3
The Fed defines smaller banks as those outside of the top 25 by domestic assets.
30 March 2023 4
outstanding at US banks (Figure 4). In general, such exposures are inversely proportional to
their size; smaller banks tend to have a higher percentage of their total loans in commercial
mortgages (CML) than larger ones. The Fed stress-tests the CML portfolios held by banks with
more than $100bn of total assets, and the results indicate that capital levels are sufficient to
absorb credit losses even in a severe case. However, CML asset quality is likely to deteriorate as
the loans mature into an elevated cap rate environment. We believe banks may be inclined to
extend maturity dates to prevent large-scale mark to market events, but that would be subject
to negotiation with the borrower.
FiGUrE 3. Holders of CrE mortgages outstanding FiGUrE 4. CrE loan exposure at US banks
As of 4Q22. All US commercial banks.

Source: Federal Reserve, Barclays Research Source: Call reports, Barclays Research
European banks are liquid and well capitalized

We think recent sector moves are overdone for European Banks and see them as well
positioned from both liquidity and capital perspectives. Of the two, we think liquidity could
receive more regulatory focus, noting that banks have capital well ahead of minimum levels and
appear able to withstand interest rate shocks.
How vulnerable are European banks to deposit outflows?

We think the contagion risks for European banks from challenges in the US are limited and see
Credit Suisse as an idiosyncratic case. As such, we find it hard to fully rationalise the recent
sector moves, although we appreciate market participants are nervous following recent events.
While we think European banks are in a strong liquidity position, weak market confidence may
result in pressure for increased regulation. For more, see European Banks Topics: European
Banks and DBK: In the Woods, 27 March 23.
European banks do not have the same problems as the US regional banks or CS, for a
number of reasons, including their liquidity4 levels (Figure 5), differences in customer behaviour,
differences in monetary policy, differences in exposures and differences in accounting.
Nevertheless, they have struggled to achieve cost of equity returns, leading to some inherent
instability, and like all banks globally, they are dependent on the confidence of their customers
and counterparts. We think things will get better, but it will take time.
Liquidity rather than solvency requirements in focus for the sector, also the supervisory
toolkit. Given recent events, it is highly unlikely that liquidity regulation will be eased any time
soon, even in countries such as the UK, which is looking to relax banking regulation post-Brexit.
4
How do we measure liquidity? Primarily we refer to the liquidity coverage ratio (LCR), a ratio of high quality liquid
assets (or HQLA) over deposit outflowsestimates, which are weighted for different types of liability. On average, the LCR
is currently about 160% for European banks.
30 March 2023 5
However, it is unclear whether regulation remains in status quo or intensifies; there could be an
argument to tighten the rules about which assets can be classified as high-quality liquid assets
(HQLA) and increase the assumptions regarding deposit outflows, given the excess liquidity now
in the system and lessons from the CS experience.
We therefore ran scenarios for higher liquidity requirements via a tougher LCR calibration,
although we would expect any changes to take time to be implemented. Nevertheless, it is not
clear that this would fix today’s issues, as money can move very rapidly.
FiGUrE 5. regional LCrs: how Europe compares

180% LCR over time by region, %
170%
Europe
160%
Americas
150% Rest of the world
140%
130%
120%
110%
100%
Dec-12 Dec-13 Dec-14 Dec-15 Dec-16 Dec-17 Dec-18 Dec-19 Dec-20
Source: Basel Committee on Banking Supervision (note: consistent sample of Group 1 banks over time), Barclays Research
FiGUrE 6. The average liquidity coverage ratio for European Banks is c160%
300% FY 22 LCR, %
250%
200%
Average 161%
150%
100%
50%
0%
BIRG
Danske
DKB
ING
Lloyds
SEB
OSB
*SAN
UCG
VMUK
AIB
StanC
ABN
CS
DNB
*Caixa
SHB
UBS
NatWest
Metro
Nordea
Swedbank
BNP
HSBC
SocGen
*Not covered by Barclays Research.

Source: Company data, Barclays Research
Scenario 1: The CS Q4 22 experience

if the calibration of stress outflows for European Banks changed to the level that CS had in
Q4 22 (over a quarter, rather than 30 days), LCrs would be reduced c.35% on average, to
c.125%. We assume that in this scenario, HQLAs are reduced from outflows, but that the
potential cash outflows are also reduced, as the least sticky deposits exit banks.
30 March 2023 6
FiGUrE 7. in a Credit Suisse comparable scenario, we think the average LCr in the sector could be
reduced from c.160% to c.125%...
275% LCR ratio estimated based on Credit Suisse 4Q outflow experience
250%
225%
200%
175%
150%
125%
100%
75%
50%
25%
0%
*Not covered by Barclays Research

Source: Barclays Research
FiGUrE 8. ...compared with CS’s LCr decreasing 25%, from 194% to 144% Q3 vs. Q4
Pp change in LCR based on Credit Suisse 4Q outflow experience
vs. FY22 reported
0%
-25%
-50%
-75%
-100%
SEB
DKB
*SAN
ING
Danske
AIB
DNB
BIRG
Lloyds
UCG
VMUK
SHB
SocGen
StanC
Nordea
NatWest
BNP
Metro
Swedbank
*Caixa
ABN
UBS
HSBC
Source: Barclays Research estimates
Scenario 2: The original regulatory proposal

The initial consultation paper on LCR from the Bank of International Settlements shows that a
higher weighting for deposits in the cash flow calculation was originally proposed. As the LCR is
calculated as HQLA over the potential net cash outflows, a higher weighting applied to deposits
would increase the potential cash flows and therefore reduce the LCR.
Figure 9 shows how the assumptions in the original consultation paper for the main
subcategories used in the calculation of cash outflows compare with the average assumptions
banks used in FY22; the original proposal is indeed more conservative.
30 March 2023 7
FiGUrE 9. Assumptions proposed under the original BiS consultation paper were more conservative
than the average ones that banks use in the LCr calculation
Average assumptions used by

Original proposal
banks at FY22
retail deposits
Stable deposits 7.5% 5.0%
Less stable deposits 15% 12%
Wholesale funding
Operational deposits 25% 25%
Non-operational deposits 75% 57%
Unsecured debt 100% 99%
Source: Company reports, BIS consultation paper, Barclays Research
The stricter proposals would also reduce the average LCr in the sector by c.35%. We
assume HQLAs and cash inflows remain unchanged, but cash outflows in the LCR calculation
increase. This is a similar order of magnitude to the CS scenario in aggregate, although the mix
of what is affected the most is different.
FiGUrE 10. Under the original liquidity proposals, the average LCr in the sector would be c.125%...
200%
Pro-forma FY22 LCR under original Basel proposal %
175%
150%
125%
100%
75%
50%
25%
0%

FiGUrE 11. ...reducing the LCrs about 35% on average

25% Pp change in FY22 LCR under original Basel proposal vs. reported
0%
-25%
-50%
-75%
-100%

if the banks want to maintain their current LCr on the stricter proposals, they would need
to increase their HQLAs by an average of c.25%. Some of the Nordic banks (notably
Swedbank and SEB) screen well, with the weighting of wholesale funding already higher than
30 March 2023 8
the original proposals. The Irish banks appear to require the highest increases in HQLA, driven
by a higher proportion of non-operational wholesale deposits than many peers (for which the
outflow weighting is typically increasing to 75% from 50%), albeit they are likely to have
mitigating factors in the form of meaningful deposit growth as the Irish banking market
consolidates.
This could translate into an average reduction of loans of c.10%. All else equal, we assume
the banks would need to change the use of deposits to increase the amount of HQLAs. In
particular, we assume they will fully address the shortfall by reducing loans and instead just
hold as cash.
This could equate to a pro forma reduction in FY22 underlying PBT of c.15%. For simplicity,
we assume “lost” NII equivalent to a 200bp spread over the funding rate on lending.
FiGUrE 12. We think stricter norms might require an average increase FiGUrE 13. ...which if all came from a reduction in loans, would need
of c.25% to HQLA to maintain existing LCrs... an average c.10% reduction in lending and c.15% off FY22 underlying
PBT
50% Implied increase in HQLA required, % 5% Pro-f change in FY22 loans to maintain LCR, %
40%
0%
30%
-5%
20%
-10%
10%
-15%
0%
-10% -20%
BIRG
*SAN
Danske
ING
AIB
VMUK
StanC
Lloyds
Metro
SEB
SEB
*Caixa
UCG
SocGen
Lloyds
VMUK
ING
*SAN
Danske
StanC
BIRG
AIB
NatWest
Nordea
DBK
DNB
SHB
Swedbank
HSBC
UBS
Average
UCG
ABN
SHB
*Caixa
BNP
DNB
Metro
NatWest
UBS
Swedbank
ABN
DBK
Average
BNP
SocGen
HSBC
Nordea
*Not covered by Barclays Research *Not covered by Barclays Research. Pro forma effect on FY22 loan
Source: Barclays Research Source: Barclays Research estimates
What happens if liquidity does become squeezed?

If customers start to withdraw deposits, banks may need to start liquidating assets to fund the
draw-downs. Given the potential losses recognised if these are out of the money, we think there
could be an average hit to the CET1 capital ratio of c.75bp if all debt securities need to be sold;
nevertheless, on a sector basis, we think this is an unlikely outcome, with a number of other
factors at work.
30 March 2023 9
FiGUrE 14. As at FY22, if all debt securities needed to be sold, there would have been an average
c.75bp effect CET1 ratios, all else equal
CET1 ratio impact from unrealised losses on debt securities held at amortised cost,
%
0.5%
0.0%
-0.5%
-1.0%
-1.5%
-2.0%
-2.5%
-3.0%
-3.5%
-4.0%
Lloyds
BIRG
ING
AIB
SEB
Danske
RBI
UBS
CS
SHB
BNP
StanC
HSBC
NatWest
Unicredit
Santander*
CaixaBank*
Metro
SocGen
Unicaja*
Swedbank
Bankinter*
* Not covered by Barclays Research. Based on FY22.
Source: Barclays Research
Debt security losses may be hedged. There is a risk that losses on liquidation will affect the
P&L (and therefore capital) for any debt securities that are not accounted for at market value.
However, there could be hedging instruments to offset any risk. In particular, a difference in
accounting between IFRS and US GAAP makes it easier for European banks to apply hedges to
these positions.
insured deposits may help reduce the immediate need for liquidity. Across many
jurisdictions, retail and SME deposits up to a set amount are often guaranteed/insured by local
governments. This should help reduce immediate bank liquidity needs, as customers should
not need to withdraw deposits. However, this alone may not be sufficient to stem a run on a
bank in a period of stress; depositors may require immediate liquidity (rather than wait for
insurance payouts) and/or may not act rationally in a period of weak sentiment.
Central banks have a role to play in providing lines of liquidity. The Swiss National Bank has
provided a line of liquidity of about CHF100bn to support UBS’s takeover of CS, which should
increase confidence in the stability of the financial system. As a matter of course, the Bank of
England offers the Indexed Long-Term Repo operation, which allows banks to borrow cash for a
six-month period in exchange for less liquid assets such as debt securities. The latter act as
collateral, giving the benefit to the banks without having to realise potential losses through a
fire-sale liquidation.
in Europe, this may be difficult. While analysing the change of the TLTRO conditions
(European Banks: Farewell to TLTRO arbitrage, 20 October 22), we commented on the need for
the ECB to consider a LTRO in H2 23 as a liquidity backstop. This could be now even more in
focus. An LTRO (coupled with amendments in the collateral rules, if deemed necessary) could
create a European safety net around Switzerland with a multiplier effect on the SNB’s direct
support. It would need to have no stigma attached and should not leave room for arbitrage, so
it might be complex to calibrate.
30 March 2023 10
FiGUrE 15. On average, the European listed banks have c.60% of deposits insured
Estimated proportion of uninsured deposits, %
100%
80%
60%
40%
20%
0%
UniCredit
Santander*
SEB
SocGen**
NatWest**
BBPM
StanC
BPER
Lloyds
BIRG**
Swedbank
ING
BNP**
BBVA*
AIB**
KBC
VMUK**
Credit Suisse
DNB**
Metro**
ISP
HSBC
SHB**
UBS
Danske**
Nordea**
Barclays*
Caixa*,**
Deutsche**
ABN**
*Not covered by Barclays Research. **Proportion of uninsured deposits not disclosed by the company. In this case, we are using FY 22 stable retail deposits as per the LCR
disclosure as a proxy for insured deposits. This may overstate the proportion of uninsured deposits.
Source: Company reports, Barclays Research
Are European Banks well capitalised?

To pay AT1 coupons, European banks must have excess capital above minimum regulatory
requirements. This is called the maximum distributable amount (MDA) buffer and can be
considered one measure of a bank’s capital strength. All banks are well in excess of minimum
capital requirements; the unweighted average of our sample (Figure 16) is an MDA buffer of
c.460bp of RWAs, or €c.9.1bn in absolute amounts. This emphasises that major European banks
are well above bare minimum capital levels and, in our view, are capable of absorbing modest
capital shocks and to continue to pay AT1 coupons.
FiGUrE 16. MDA buffers
1,600 50,000
1,400 45,000
1,200 40,000
35,000
1,000 30,000
800 25,000
600 20,000
400 15,000
10,000
200 5,000
0 0
Millennium BCP
ABN AMRO
Virgin Money UK
Banco Sabadell
Lloyds
ING
Credit Agricole SA
Santander UK
SEB
BBVA
AIB
Danske Bank
Bankinter
Rabobank
KBC
RBI
Caixabank
Bank of Ireland
Santander
Unicredit
Nordea
Intesa Sanpaolo
Societe Generale
Standard Chartered
HSBC
DNB
BNP Paribas
Credit Suisse
Deutsche Bank
Commerzbank
UBS
Belfius
Nationwide
Handelsbanken
Banco BPM
Swedbank
Erste Bank
Natwest Group
CredAg Group
MDA Buffer (€mn), RHS MDA Buffer (bp), LHS
Source: Q4 company disclosures where available, Barclays Research

MDA buffers are set to decline over time, due to a mix of banks targeting lower CET1 ratios in
their strategic plans and regulators setting higher capital requirements. For example, the
counter-cyclical capital buffer is already increasing in some jurisdictions, such as the UK and
Sweden (Figure 17), with rates of 2% expected in 2023. Core European countries (eg, France and
the Netherlands) look set to follow at a more gradual pace, while periphery countries, such as
Italy and Spain, have not yet planned an increase above the current 0%. Ultimately, we are not
concerned by European banks operating at levels with slightly lower MDA buffers; we also think
regulatory intervention could occur to relax capital requirements (as per 2020) if this looked to
become a pressure point for banks.
30 March 2023 11
FiGUrE 17. Counter-cyclical capital buffer by country
Country implementation Date CCyB rate (%)
Austria 1 January 2016 0

Belgium 1 April 2020 0
Denmark 31 December 2022 2
Denmark 31 March 2023 2.5
Finland 16 March 2015 0
France 1 April 2020 0
France 7 April 2023 0.5
Germany 1 February 2023 0.75
Ireland 1 April 2020 0
Ireland 15 June 2023 0.5
Ireland 24 November 2023 1
Italy 1 January 2016 0
Netherlands 1 January 2016 0
Netherlands 25 May 2023 1
Norway 31 December 2022 2
Norway 31 March 2023 2.5
Portugal 1 January 2016 0
Spain 1 January 2016 0
Sweden 29 September 2022 1
Sweden 22 June 2023 2
UK 13 December 2022 1
UK 5 July 2023 2
Source: ESRB, BoE, Barclays Research
European banks extensively manage their interest rate risk so that it is not a major source of
volatility in capital ratios. Since 2017, the ECB has emphasised that European banks should
proactively manage interest rate risk on their banking books; European banks model their
change in economic value of equity (EVE) and projected net interest income (NII) sensitivities
under six interest rate scenarios: parallel up, parallel down, steepener, flattener, short rates
shock up, and short rates shock down. Figure 18 shows reported maximum EVE sensitivity
(among the six scenarios) as a percentage of banks’ Tier 1 capital. Scenario modeling likely
differs across banks, so like-for-like comparisons may not be suitable; however, it does highlight
that European bank capital ratios are resilient to interest rate shocks.
30 March 2023 12
FiGUrE 18. Maximum EVE as % of Tier 1 capital
0%
-2%
-4%
-6%
-8%
-10%
-12%
-14%
-16%
-18%
-20%
Last reported disclosures as of 16 March, maximum EVE change highlighted.

Source: Company disclosures, Barclays Research
US regional banks likely to tighten lending standards

Regulators have indicated their concern about the possibility that if funding volatility continues
to stress banks, credit could become more expensive and less available. We believe market
concerns about deposit outflows will persist, but most US regional banks will be relatively
resilient to the stress, particularly with the Fed’s BTFP providing a liquidity cushion. Although
there are numerous ways that banks could accommodate potential deposit outflows, we view
outright asset sales as unlikely, given the role they played in crystallizing losses during SVB’s
demise.
Alternatively, regionals could allow increases in their loan-to-deposit ratios, which currently sit
at very low levels by historical standards (Figure 19). We view this as the most likely outcome,
with regionals becoming somewhat more circumspect in growing their loan books, but not
drastically reining in credit provision. Although most would still likely have ample lending
capacity from deposits, funding pressures would likely increase the cost of the credit they
provide, thereby contributing to tighter aggregate credit conditions.
FiGUrE 19. Loan-to-Deposit ratios (%) for Banks Are Still relatively FiGUrE 20. C&i Lending and Unused Capacity % Total Assets
Low
Net loans & leases to total deposits, as calculated by the FDIC. BHC level only. Regionals here defined as all BHCs with >$10bn in total assets,
excluding US GSIBs and Yankee banks.
Source: FDIC, Barclays Research Source: Company filings, S&P Capital IQ, Barclays Research
Regional banks are important commercial and industrial (C&I) lenders and held 45% of such
balances outstanding as of YE 22. Most C&I lending is concentrated at the largest regionals
30 March 2023 13
(Figure 20). Small and mid-sized businesses (SMEs) are particularly dependent on regionals for
credit and other financial services, as large corporates generally can borrow directly from credit
markets. Hence, a pullback in credit by regionals would likely disproportionately affect these
smaller companies.
Until now through this hiking cycle, SMEs have been resilient and default rates on their loans
have remained relatively low. However, if regionals are less able to commit balance sheet to
lending, their corporate customers would either need to find viable replacements or bear the
risk of operating with diminished access to credit. The degree to which regional banks pull back
credit would depend on many factors, including the severity of potential deposit outflows and
the extent to which banks let their loan-to-deposit ratios increase. We discuss some potential
scenarios in Regional Bank Stress: Don’t Call it a Credit Crunch (Yet).
Our economic models have difficulty estimating the effect of a lending pullback of this nature
with much precision. Much depends on whether the tightening of bank credit conditions proves
orderly – in principle, it could even support the Fed’s efforts to bring down inflation without
resorting to additional rate hikes that could exacerbate banking pressures – or disorderly,
possibly leading to a severe credit crunch that may well be augmented by broader financial
accelerator effects.
Our view, which aligns with the general conclusions from published academic research, is that
plausible degrees of tightening in credit conditions have meaningful, but not catastrophic,
effects on macreoconomic activity, albeit with the important caveat that the situation does not
morph into a full-blown crisis of confidence.
Cost of capital likely to rise

Following the events at Credit Suisse, there has been decompression in the capital stack and
CDS spread widening. After the complete write-down of CS AT1s to zero, many credit investors
are seemingly re-evaluating the risk profile of the asset class. We consider the cost of funding
across AT1, senior debt and deposits; while AT1 issuance may also be more challenging near
term, we think widening senior spreads will have a manageable effect on earnings for banks.
The real issue would be if weaker macro expectations lead to lower rate expectations.
Given that the last reported Q4 metrics of Credit Suisse were 14% CET1 and 144% LCR, which
were well above minimum regulatory levels (c.10% CET1 and 100% LCR), there seems to be
scepticism among some investors that optics of balance sheet strength do not actually provide
immunity to bank runs. Therefore credit markets have also re-priced CDS for banks such
Deutsche Bank significantly wider, especially on 24 March.
Credit Suisse sets a difficult precedent for the AT1 market

AT1 instruments should absorb losses after equity holders based on the general creditor
hierarchy. However, as noted above, CS’s CHF16bn worth of AT1 securities are being written
down to zero, while equity has retained some value. For more see European Banks Topics:
European Banks and DBK: In the woods, 27 March 23.
Given this, we expect AT1 issuance to be challenging in the near term. Despite many
regulators globally reiterating that AT1 holders should be prioritised ahead of equity holders as
per creditor hierarchy principles, investor concerns remain. Longer term, we think there could
be debate over the purpose of AT1s in the capital stack and, unless confidence is restored, see
risks for it to become a defunct capital class. This could be reinforced if banks choose not to call
instruments if new issuance costs are prohibitive.
30 March 2023 14
We see greater risk for banks with a higher proportion of AT1 of total funding overlaid with
the PBT sensitivity to higher AT1 costs; in particular, we think UBS is most at risk and could
effectively see a higher CET1 leverage requirement based on Swiss rules. Figure 21
illustrates which European banks derive a greater proportion of their tier 1 capital in the form of
AT1 securities. On average, we think an additional 100bp of AT1 cost would be a hit of c.80bp to
underlying PBT for European banks.
Nevertheless, we think the direct effect would be manageable, as the EU banks have on the
whole issued what they need based on their existing balance sheet size, so in the worst case
could simply choose not to call existing instruments (even if there is some increase in coupon).
It will take a long time for balance sheets to grow to a point where there is meaningful shortfall,
effectively pushing up CET1 requirements (to bridge the gap).
FiGUrE 21. On average, AT1 makes up just under 1% of European banks’ total funding
4.0% AT1 (Q3-22) % of total funding (Q4-22), %
3.5%
3.0%
2.5%
2.0%
1.5% 0.9%
1.0%
0.5%
0.0%
Danske
Lloyds
Natwest
StanC
*BBVA
ING
*SAB
*SAN
*Unicaja
SEB
KBC
AIB
BBPM
CS
SHB
CASA
RBI
UCG
*Caixa
Bankinter
UBS
SocGen
ISP
HSBC
DBK
DNB
BPER
CBK
BNP
ABN
BOI
SWED
ERSTE
Nordea
Total funding = Deposits + Debt + Central banks + other. * Not covered by Barclays Research
Source: Company data, Barclays Research
Effect on senior funding costs also manageable

Credit spreads have widened c.20bp on average since the start of March. But we think
regardless of the conclusion of CS/UBS, they are unlikely to return to pre-SVB levels for some
time, with sentiment having been severely rocked. Indeed, risks appear skewed to the
downside, with a chance of credit spreads increasing further if there are ongoing challenges in
the sector.
FiGUrE 22. CDS spreads have increased an average of c.20bp since the start of March, with the
potential to increase further
1.3% Change in CDS spread (Senior 5 year) vs 1st March, %

1.1%
0.9%
0.7%
0.5%
0.3%
0.1%
-0.1%
Lloyds
UniCredit
Intesa
ING
Danske
CredAg
Santander*
Sabadell*
AIB
Barclays*
Commerz
STAN
Erste
KBC
ANB AMRO
SEB
MPS
SHB
Bank of Ire.
BBVA*
HSBC
BAMI
CaixaBank*
Swedbank
UBS
SocGen
Average
RBI
BNP
NatWest
DNB
Nordea
Deutsche
. *Not covered by Barclays Research.

Source: Bloomberg pricing (as at 23 and 24 March 2023 vs. 01 March 2023), Barclays Research
30 March 2023 15
Taking company guidance on issuance expected in FY 23 (excluding anything already

completed), we assume that widening CDS spreads directly correspond to a higher cost of
issuance and look at two scenarios:
1. CDS spreads remain at current, elevated levels for the rest of year: we think this would
take an average of c.40bp off EPS and c.30bp off FY23e underlying PBT.
2. CDS spreads increase further, +100bp versus these levels: we think this would take an
average of c.190bp off FY23 EPS and c.150bp off underlying PBT.
In our analysis, we consider the incremental cost of wider spreads; we assume that costs of
issuance at pre-SVB spreads are already factored into earnings estimates. We also apply these
spreads to the issuance volumes the banks have indicated in their funding plans for this year.
Deposit funding costs also likely to rise

Currently, banks are benefiting from a higher interest rate backdrop, with wide margins
on deposits. Over 2022, the ECB depo rate had risen 2.5%, but on average across Europe, banks
had passed on only c.20% of this to depositors (the “deposit beta”). That is, on average, deposit
rates had increased only an average of 50bp, with banks effectively holding onto the other
200bp as income. The US fares no better, with a deposit beta of 30%, with a 4.25% rise in the fed
funds rate in 2022.
But if the banks start to see deposit outflows, they may need to increase deposit rates. As
discussed above in European banks are liquid and well capitalized, there is a risk that liquidity is
reduced, given sentiment. If there is pressure on outflows, banks may need to pay up to
maintain their funding levels, especially if this is cheaper than wholesale funding. In particular,
there is a risk that depositors could become more rate sensitive as interest rates rise and see
opportunities for significantly better yield in savings accounts, term deposits or elsewhere in
wealth and money markets.
With deposit betas so low, the market is ripe for increased competition. Comparing the
current hiking cycle with that of 2005-08, the deposit beta is now only c.20bp. Last time at the
start of cycle it was c.25bp and increased to c.60bp. As such, we think betas are likely to rise. But
even adding in an element of competition, with banks paying higher deposit rates to stem any
potential deposit outflows, we think the banks can still price rationally and generate revenue.
On the other hand, a perceived safety factor may benefit selected banks. In the current
period of stress, there is a view that depositors will forego a higher yield on deposits in favour of
a bank with better perceived liquidity/quality; these are typically large-cap, well-established
banks with a long track history (for example, HSBC). In such cases, these banks may not suffer
deposit outflows but in fact receive inflows, may not need to compete for deposits and may
even be able to lower deposit costs.
30 March 2023 16
FiGUrE 23. ECB depo rate in the previous rate hike cycle and the current one
Current hike
Previous hike
4.0 ECB depo rate May 06 (hike start)
3.5
3.0
2.5
2.0
1.5
1.0
0.5
0.0
-0.5
-1.0
Mar-01
Mar-08
May-09
Mar-15
May-16
Jun-99
Feb-04
Sep-04
Jun-06
Sep-11
Jun-13
Feb-18
Sep-18
Jun-20
Aug-00
May-02
Aug-07
Feb-11
Aug-14
Aug-21
Mar-22
Oct-01
Nov-05
Apr-05
Oct-08
Nov-12
Apr-12
Oct-15
Apr-19
Nov-19
Oct-22
Dec-02
Jul-03
Dec-09
Jul-10
Dec-16
Jul-17
Jan-00
Jan-07
Jan-14
Jan-21
Source: Bloomberg, Barclays Research
FiGUrE 24. in the previous hiking cycle, deposit betas rose to c.60bp FiGUrE 25. ...compared with c.20bp now
on average...
50%
150% Deposit beta, % Deposit beta, %
125% 40%
100%
30%
62% 19%
75%
20%
50% 25%
25% 10%
0%
0%
SE NL GE FI IE ES PT BE AT DE FR IT
Sep 08 (hike end) May 06 (hike start) SE NL FR FI IE AT BE IT DE ES PT GE
EZ Sep 08 EZ May 06 Dec 22 (hike start) EZ Dec 22
Note: SE: Sweden, NL: Netherlands, GE: Greece, FI: Finland, IE: Ireland, ES:Spain, PT: Note: For Sweden, see also our note, 02 March 2023. There deposit betas are
Portugal, BE: Belgium, AT: Austria, DE: Germany, FR: France, IT: Italy calculated at the single-bank level but only for households, which explains the
difference vs. our sector aggregate statistics
Source: ECB, Barclays Research Source: ECB, Barclays Research
Higher betas could mean lower margins. Deposit flight is always an existential risk, but it is
unusual in a regulated banking system supported by a lender of last resort. The more typical
reaction to policy tightening is for banks to lift the rates they pay on deposits and feed these
through to borrowers in the form of higher credit costs and somewhat tighter lending
conditions. We think deposit betas are poised to increase at a faster pace, especially for US
regional banks.
After being slow to pass through higher base rates to depositors (see US Money Markets: Deposit
departure), regionals will likely be quicker to increase them to preserve or bolster their core
funding base. This would pressure profit margins and might well feed into higher lending rates.
This is a far less worrisome risk for regionals than extreme deposit flight, but it could reduce
their ability to compete with the moneycenter GSIB banks, which have been largely unaffected
by this crisis.
30 March 2023 17
FiGUrE 26. Deposit Beta vs. Fed Funds
Cumulative Beta (solid line) Avg Fed Funds (dotted line)

70% 7.00%
60% 6.00%
50% 5.00%
40% 4.00%
30% 3.00%
20% 2.00%
10% 1.00%
0% 0.00%
0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Quarter post 1st hike
1st hike: 2Q99 2Q04 3Q15 1Q22
Source: Federal Reserve, S&P Global Market Intelligence, Company reports, Barclays Research
Regulatory oversight likely to tighten in the US as well

The failure of SVB could lead to changes in bank supervision and regulation. We believe any
changes are likely to be implemented thoughtfully so as to not disturb an already fragile
situation. The Federal Reserve Board recently announced that Vice Chair for Supervision
Michael Barr is leading a review of Silicon Valley Bank, which is slated to be released by May 1.
The FDIC Inspector General will also have to publish a failed bank review, as required by law. We
would expect this to lead to increased supervision and regulation for the industry as a whole
and super-regional banks in particular.
Last year, the Federal Reserve began a holistic review of bank capital requirements, with results
expected later this year. It is also implementing enhanced regulatory capital requirements that
align with the final set of Basel III standards issued in December 2017. We believe recent events
could play a role in both outcomes, potentially expanding the number of banks that get
covered, enhancing capital and liquidity ratio calculations and increasing minimum
requirements.
A re-think of “risk” under the tailoring framework

In 2019, the Federal Reserve established a “tailoring” framework, in an effort to match
regulations to a bank’s risk profiles more closely. This was done in response to the House and
Senate passing the Economic Growth, Regulatory Relief, and Consumer Protection Act
(EGRRCPA or S.2155), with bipartisan support. The rules maintain the most stringent
requirements for the largest banks, while reducing compliance requirements for smaller ones.
Those with assets over $100bn were divided into four categories based on several factors,
including asset size. While Category I banks, which covers the eight global systemically
important banks in the US, have the most stringent capital and liquidity requirements, recent
events could cause the Federal Reserve to apply these to lower-tiered institutions and perhaps
decrease the minimum asset threshold. This could be particularly true for liquidity ratios. It
could look to modify scenarios in its annual stress test to capture interest rate and duration risk
more comprehensively, also raising bank capital requirements.
30 March 2023 18
reporting requirements may also need to be reconsidered

Recent events could also increase the emphasis the Federal Reserve places on unrealized losses
in banks’ AFS and HTM securities portfolios. Accumulated other comprehensive income (AOCI),
which is driven by unrealized AFS losses, is currently included only in the Category I bank
regulatory capital ratios, while unrealized HTM losses are excluded for all. Had SVB included
both metrics in its capital calculation, it would have showed it had negative equity. By
comparison, The remainder of the top 20 banks are all above or very near the 4.5% regulatory
minimum capital ratio requirement (as a percent of risk-weighted assets).
While there are regulatory requirements for capital and liquidity, reporting for interest rate risk
is not uniform. Still, we expect improved disclosures and heightened attention to this area in
regulatory examinations, which could become more stringent, with regulators potentially
taking actions sooner and more forcefully than in the past. SVB had been issued multiple
private citations leading up to its failure, but they were not fully acted upon in a timely manner5.
Potential expansion of TLAC requirements

In October 2022, the Federal Reserve and FDIC issued a proposal to expand total loss absorption
capacity (TLAC) requirements (Initial Proposal Released for Regional Bank TLAC), which include
a mandatory long-term debt (LTD) minimum requirement (“bail-in” capital), to a broader group
of banks than just the largest ones. These were designed to enhance regulators’ ability to
resolve large banks in an orderly way should they fail. Recent actions increase the probability
that this construct is applied to a wider pool of banks. While it initially appeared geared for
banks with more than $250bn in assets, we believe it could be expanded to those with $100bn-
plus in assets.
increased regulation supports credit quality, but with trade-offs

Longer term, US banks are likely to face more stringent regulatory requirements, given recent
calls by politicians for enhanced oversight of regionals in particular, and as discussed above.
While these measures would make them safer, they could come at the expense of a higher cost
of funding and capital, as well as second-order implications for their customers (Regional Bank
Stress: Don’t Call it a Credit Crunch (Yet)).
5
Statement by Michael Barr, Vice Chair for Supervision, Board of Governors of the Federal Reserve System before the
Senate Committee on Banking, Housing, and Urban Affairs, March 28, 2023
30 March 2023 19
FiGUrE 27. Federal reserve Tailoring rule, Current Construct
Category Category I Category II Category III Category IV

≥ $700b assets or ≥ $75b
≥ $250b assets or ≥ $75b
Description U.S. GSIBs in cross jurisdictional $100-$250bn in assets
in nonbank assets
activity
BAC, BK, C, GS, JPM, MS, ALLY, CFG, FITB, HBAN,
Select Bank Tickers NTRS COF, PNC, TFC, USB
STT, WFC KEY, MTB, RF
Capital
GSIB surcharge Yes No No No
Countercyclical capital buffer (CCyB), if deployed Yes Yes Yes No
Opt-out of AOCI recognized in capital No No Yes Yes
Stressed capital buffer (SCB) calculation Annual Annual Annual Biennial (even years)
Supplementary leverage ratio (SLR) Enhanced Yes Yes No
TLAC/long-term debt Yes Proposed Proposed No
Liquidity
Liquidity coverage ratio (LCR) Yes Yes Reduced (85%) Reduced (70%)
Net stable funding ratio (NSFR) Yes Yes Reduced (85%) Reduced (70%)
Liquidity stress test (internal) Monthly Monthly Monthly Quarterly
FR 2052a reporting (internal) Daily Daily Monthly Monthly
Other
Risk Committee Yes Yes Yes Yes
Single-counterparty credit limits (SCCL) Yes Yes Yes No
Source: Barclays Research, Federal Reserve
30 March 2023 20
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We, Amit Goel, Jason M. Goldberg, CFA, Peter Troisi, Grace Dargan, Paola Sabbione, Soumya Sarkar and David Alam, hereby certify (1) that the views
expressed in this research report accurately reflect our personal views about any or all of the subject securities or issuers referred to in this research
report and (2) no part of our compensation was, is or will be directly or indirectly related to the specific recommendations or views expressed in this
research report.
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30 March 2023 22
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Barclays US and European Banks Shaken, and Stirred

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Special Report

US and European Banks

Shaken, and stirred FOCUS

A case of duration mismatch at Silicon Valley Bank

The search for yield

1Q20 1Q21 1Q22

When all things collided, and failed

A series of unfortunate events for Credit Suisse (CS)

CS continued to be the subject of a significant amount of negative headlines in 2023. Although

We believe US banks are well supported in face of

Failures were isolated and should remain so

Asset quality will be in focus over the medium term

As of 4Q22. All US commercial banks.

European banks are liquid and well capitalized

How vulnerable are European banks to deposit outflows?

FiGUrE 5. regional LCrs: how Europe compares

*Not covered by Barclays Research.

Scenario 1: The CS Q4 22 experience

*Not covered by Barclays Research

Scenario 2: The original regulatory proposal

Average assumptions used by

Source: Company reports, BIS consultation paper, Barclays Research

*Not covered by Barclays Research

FiGUrE 11. ...reducing the LCrs about 35% on average

*Not covered by Barclays Research

What happens if liquidity does become squeezed?

Are European Banks well capitalised?

FiGUrE 16. MDA buﬀers

MDA Buffer (€mn), RHS MDA Buffer (bp), LHS

Source: Q4 company disclosures where available, Barclays Research

FiGUrE 17. Counter-cyclical capital buﬀer by country

Country implementation Date CCyB rate (%)

Austria 1 January 2016 0

Source: ESRB, BoE, Barclays Research

FiGUrE 18. Maximum EVE as % of Tier 1 capital

Last reported disclosures as of 16 March, maximum EVE change highlighted.

US regional banks likely to tighten lending standards

Cost of capital likely to rise

Credit Suisse sets a diﬀicult precedent for the AT1 market

Eﬀect on senior funding costs also manageable

1.3% Change in CDS spread (Senior 5 year) vs 1st March, %

. *Not covered by Barclays Research.

Taking company guidance on issuance expected in FY 23 (excluding anything already

Deposit funding costs also likely to rise

FiGUrE 26. Deposit Beta vs. Fed Funds

Cumulative Beta (solid line) Avg Fed Funds (dotted line)

Regulatory oversight likely to tighten in the US as well

A re-think of “risk” under the tailoring framework

reporting requirements may also need to be reconsidered

Potential expansion of TLAC requirements

increased regulation supports credit quality, but with trade-oﬀs

FiGUrE 27. Federal reserve Tailoring rule, Current Construct

Category Category I Category II Category III Category IV

Source: Barclays Research, Federal Reserve

Barclays Capital Canada Inc. (BCCI, Canada)

Disclosure of other investment recommendations produced by Barclays FiCC research:

Barclays Bank Ireland PLC, Paris Branch (BBI, Paris)

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